Dear RHP 2 Performing Providers and Stakeholders:
Attached are the anchor call notes from the call hosted by HHSC on Friday, October 24th.
October 2014 archive
Dear RHP 2 Performing Providers and Stakeholders:
Permanent link to this article: https://blogs.utmb.edu/1115/2014/10/27/anchor-call-notes-102414/
Good Afternoon Region 2:
In an effort of full transparency, I am sharing with RHP 2 Performing Providers (and those stakeholders who have requested such communication) the following update from HHSC regarding the ongoing Uncompensated Care (UC) review. As previously announced, CMS has stated it will “defer” federal funds for Uncompensated (UC) payments for private hospitals that are in certain funding arrangements that CMS believes may be unallowable uses of provider-related donations. More details can be found on the HHSC website and in the letter I published for RHP 2 on Tuesday, October 7, 2014 (https://blogs.utmb.edu/1115/category/hhsccms-news/).
The information below from HHSC was shared with anchors and other parties on Friday, October 17, 2014 in advance of a UC update call hosted by Ms. Pam McDonald, Director, HHSC Rate Analysis and other key HHSC staff members from both Rate Analysis and the 1115 Waiver team. This, once again, supplements prior information covered in my above-mentioned communication from Tuesday, October 7, 2014 as well as any prior communication from the State on/before Friday, October 17, 2014.
At this point, we have not learned of any impact to DY3 October Reporting due to the ongoing UC issue. As such, Performing Providers should continue their plans to submit their reporting tool to HHSC on/before the (extended) deadline of Wednesday, November 5, 2014 at 11:59 p.m.
As we learn more, we will share with our regional providers and interested stakeholders. If you have additional questions or require further assistance, please contact me personally at: email@example.com or 409.766.4047.
Uncompensated Care (UC) Deferral Issue – Talking Points
HHSC Hosted Call:
Friday, October 17, 2014, 1:00 PM CST
- Removal of 8 private hospitals and 1 public hospital from the deferral list and reduction of deferral by $11.7M FF.
|Baylor Medical Center at Waxahachie|
|Scott & White Hospital – Llano|
|Scott & White Healthcare- Round Rock|
|CHCA Bayshore LP dba Bayshore Medical Center|
|Christus Health ARK-LA-TEX dba Christus St. Michae|
|CHRISTUS St. Catherine Hospital|
|Christus Health Gulf Coast dba Christus St. John H|
|Christus Health Southeast Texas dba Christus St. E|
|Lavaca Medical Center|
- HHSC meeting this week with attorneys/consultant representing many of the entities involved with the 501s, discussion of strategy, agreement to share information, etc. Strategy could include:
- Prove there were no donations
- Provide documentation proving everything was disclosed to and recognized by CMS in 2008
- Equity/Access-to-care argument
- Face-to-face meeting with Cindy Mann
- Contacts from Texas Legislative delegation, state legislators with ties to the Obama administration, etc.
- Individual meetings/calls with various impacted entities to gather info requested by CMS.
- Working on request to CMS for:
- Identities of individuals representing to CMS that public entities would not provide IGTs for private entities if private entity had not provided payment to public entity or 501 and notes of these statements.
- Explanation of how HHSC can adequately address CMS’s concern that entities were not forthcoming with documents. What documents or evidence must HHSC obtain from providers if those providers have no relationship with the questioned 501 or no documents exist?
- List of documentation HHSC must provide to ensure that waiver supplemental payments continue without future threat of deferral or disallowance.
- HHSC staff briefing with HHSC leadership next week to present strategy for feedback and approval.
Permanent link to this article: https://blogs.utmb.edu/1115/2014/10/22/update-talking-points-from-hhsc-on-cms-uc-deferral-letter/
RHP 2 Providers and Stakeholders:
If possible, plan to join us for a brief conference call on Monday, October 13, 2014 at 1:00 pm (details below). We will cover updates received from HHSC’s anchor call today.
Date: Monday, October 13, 2014
Time: 1:00-1:30 pm
Access Code: 3020674
Permanent link to this article: https://blogs.utmb.edu/1115/2014/10/13/rhp-2-conference-call-hhsc-updates-monday-october-13/
Thank you to everyone who participated in the RHP 2 October reporting call. Attached is the document [Talking Points] containing the talking points that were discussed, and note that we will be updating this list as new information/clarification comes in from HHSC.
Susan Seidensticker, BSIE, MSHAI, CPHQ, CSSBB, PMP
Director, Waiver Quality Operations
University of Texas Medical Branch (UTMB)
Shearn Moody, 9th Floor
Permanent link to this article: https://blogs.utmb.edu/1115/2014/10/09/rhp-2-october-reporting-call-10-09-14/
IMPORTANT Region 2 Update: Notice of deferral of Federal Funds Relating to Certain Private Hospital Payments
Dear Region 2:
I wanted to provide an update on an important issue we learned about last week from HHSC leadership. In a [letter] dated September 30, 2014, CMS has stated it will “defer” federal funds for Uncompensated (UC) payments for private hospitals that are in certain funding arrangements that CMS believes may be unallowable uses of provider-related donations. I have outlined a summary of the situation below. The [letter] attached provides the additional background.
- In May, CMS issued a letter to state Medicaid directors which discussed guidance related to provider related donations (letter attached).
- This summer, CMS conduced a financial management review of the 1115 waiver in RHP’s 4, 7, 9 and 10. During this review, CMS identified certain funding arrangements it believes constitute the unallowable use of provider-related donations.
- CMS has questions regarding the source of the non-federal share of these expenditures. In particular, CMS would like to explore further the understanding of the financing mechanism being utilized and its intersection with the recent guidance issued in State Medicaid Director Letter #14- 004 on May 9, 2014. It appears that the intergovernmental transfer (IGT) may be derived from funds that the government entity previously would have spent on providing the services that are now being provided/funded by the private entity and/or direct payments made to the governmental entity from private entities.
- Last week, CMS issued a letter indicating that they will defer the federal expenditures in the regions reviewed – a total of $74,891,536 – until the source of the non-federal share is determined appropriate.
- HHSC has a call with CMS today, Monday, October 6, 2014, to discuss the deferral further and try to better understand what documentation must be submitted.
- At this time, UC and DSH payments are “on hold.” HHSC indicates that it has made no determination about DSRIP payments; but, the state hopes that this will be resolved before the next DSRIP payments are made in January (based on DY3 October reporting.)
- HHSC indicates that a similar deferral of federal funds occurred in 2007/08, relating to the same issue, and it took approximately a year to resolve the issue. The ultimate result of the review at that time was the release of the federal funds.
A few other pieces of information HHSC passed along about CMS comments:
- CMS indicated that source of IGT for DSRIP payments would be under the same scrutiny.
- CMS has indicated that they believe this is a statewide issue, not isolated to just the four (4) regions audited.
- CMS stated that during the financial review, private hospitals were not forthcoming about the amount of money they are contributing to the not-for-profit organizations and their role in providing these services.
– Although the safeguards are still in place from the 2007/08 review, CMS has noted that they may need to take a fresh look at these relationships (arrangements) based on the State Medicaid Director Letter #14- 004, dated/issued on May 9, 2014.
We will continue to share information as we received it in our anchor office; and, in full transparency, wanted to share the above knowledge with the region as soon as possible following the call on Friday afternoon, October 3, 2014.
If you have questions, you can contact HHSC directly or filter through my office.
Permanent link to this article: https://blogs.utmb.edu/1115/2014/10/07/mportant-region-2-update-notice-of-deferral-of-federal-funds-relating-to-certain-private-hospital-payments/
Part of UTMB’s commitment as anchor of RHP 2 is to coordinate efforts to share information regionally; therefore, please see the announcement on a very important and timely presentation regarding the Ebola outbreak. I apologize for the short notice, but if you are able to join us Friday, October 3, 2014, Dr. Tom Ksiazek will be presenting live in the Main Auditorium of Levin Hall, located at 10th and Market Street in Galveston. UTMB also plans to stream the presentation live and record it for YouTube viewing.
To view the Ebola lecture online, please use the following links:
Apple QuickTime Viewers: http://22.214.171.124/stream.sdp
Windows Media Viewers: http://126.96.36.199:8080/stream
If technical assistance is required, please call 409.747.9037.
Additionally, if any providers in the region have specific questions regarding the Ebola crisis, the Office of Waiver Operations will happily facilitate a discussion with one of UTMB’s experts on the topic. We are very fortunate in RHP 2 to have some of the world’s leading researchers and experts who are most willing to serve as a resource with our regional providers. If you have questions, please let me know: firstname.lastname@example.org or 409.766.4047.
Permanent link to this article: https://blogs.utmb.edu/1115/2014/10/02/1115-waiver-rhp-2-providers-invited-to-join-ebola-outbreak-presentation/